United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
Table of Contents Page
GLOSSARY OF ABBREVIATIONS ............................................................................................... 1 1. Background ................................................................................................................. 2 1.1 Introduction ............................................................................................................. 2 1.2 Audit Scope .............................................................................................................. 4 1.3 Assignment Objectives .............................................................................................. 5 1.4 Methodology ............................................................................................................ 7 2. Summary of Findings .................................................................................................... 9 2.1 Islamic Relief Kenya ................................................................................................ 10 2.2 Islamic Relief Somalia .............................................................................................. 11 3. Islamic Relief Kenya - Findings on Internal Controls Systems .......................................... 12 4. Islamic Relief Somalia - Findings on Internal Controls Systems ........................................ 34
United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
1 GLOSSARY OF ABBREVIATIONS
AWP Annual Work Plan
CPAP Country Programme Action Plan
FACE Fund Authorization and Certificate of Expenditure
HACT Harmonized Approach to Cash Transfer
IP Implementing Partner
IRK Islamic Relief Kenya
IRS Islamic Relief Somalia
PCA Project Cooperation Agreement
UN United Nations
UNICEF United Nations Childrens Fund
United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
2 1. Background 1.1 Introduction
Pursuant to the UN General Assembly Resolution 56/201 on the triennial policy review of operational activities for the development of the United Nations system, a number of UN Agencies have adopted a common operational framework for transferring cash to government and non government Implementing Partners.
Under the Harmonized Approach to Cash Transfers (HACT) Implementing Partners will use common forms and procedures for requesting cash and reporting on its utilization. Agencies will adopt a risk management approach and will select specific procedures for transferring cash to partners, and undertake implementation of assurance activities to determine whether expenditures that took place were for the purpose intended.
Islamic Relief
Islamic Relief (IR) is an International NGO established in Birmingham, UK in 1984, Registered Charity No: 328158. IRs main objective is to promote sustainable social development by co-operating with local communities through relief and development programs. IR aims to help the needy regardless of race, religion or gender.
IR is an NGO in consultative status (category special) with the Economic and Social Council of the United Nations, full members of British Overseas NGOs for Development (BOND) and Disaster Emergency Committee (DEC), UK Platform of the Liaison Committee of Development NGOs to the European Union and signatories to the Code of Conduct for The International Red Cross and Red Crescent Movement and NGOs in Disaster Relief ". The majority of IRs funding is from private donations; however, we also receive support from institutions such as DFID, ECHO, WFP, EC, UNICEF and UNHCR.
Vision: A caring World where the basic requirements of people are fulfilled Mission: Islamic Relief is dedicated to alleviating the poverty and suffering of the worlds poorest people. "Whoever saved a life, it would be as if he saved the life of all mankind" Qur'an 5:32
Islamic Relief Kenya
Islamic Relief Kenya (IRK) is registered under the Kenyan government NGO board (Reg. No. OP. 218/051/204/0374/3386) and opened offices in Nairobi and Mandera to run its emergency programme in Mandera district as of 1 st March 2006. IRK is currently involved in drought recovery, rehabilitation and development programmes.
IR has secured License No. SDGT-502 on August 19, 2005 from the USA Office of Foreign Affairs Assets Control (OFAC) that it is not among Specially Designated Global Terrorist pursuant to section 594.201 of Global Terrorist Sanction regulations, 31 C.F.R Part 594. It has also won the UK charitable organizations 2006 accountability award.
United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
3 Nationally, IRK is an active member of the Food Security Steering Group, WESCORD, Health and Nutrition working group among others. It is also a member of District Steering Group and the various thematic groups. Currently, it is chairing the District Nutrition working group meeting.
Current programmes of IRK
Health and nutrition programme:- Supplementary feeding programme, out patient therapeutic feeding programme, support to district Ministry of Health in outreach programmes and accelerated polio campaigns, Vitamin Supplementation Vaccinations, Outreach medical services, Health Education, capacity building of community health committees (CHCs) community health workers (CHWs). Most of these programmes are funded by DFID, IR-UK, UNICEF, WFP and ECHO.
Water and sanitation: - Water and sanitation facility rehabilitation / expansion, training of water resources management committees, water quality monitoring, hygiene promotion campaigns and training communities on good hygiene and sanitation practices. Funding is by UNICEF, ECHO, private donors and IR UK. IRK has rehabilitated number of water points (borehole and pans) since 2006 as funded by these donors.
Livelihood and food security: in the effort of increasing the resilience to shock through re-building the asset level of drought affected, IRK is supporting farmers in the riverine irrigation along Daua River and micro-finance. Funding for these ongoing projects is from IR private donors, ECHO, IR-UK, IR-Switzerland and Qatar Charity. It is hoped to receive support for riverine irrigation and water harvesting based irrigation from EC.
Child welfare programme: over 750 children sponsored in Mandera and each receiving 93 Euro each quarter to supplement their basic needs food, health and education needs. Funding is obtained from IR one to one sponsorship programme
Islamic Relief Somalia
Islamic Relief Somalia (IRS) is registered under the Kenyan government NGO board (Reg. No. OP. 218/051/204/0374/3386) and opened offices in Hargeisa (Somaliland) Mogadishu (South Central) and Galkacyo (Puntland) to run its emergency/Livelihood and Recovery programme in Somalia.
IR Somalia has been working in Somalia since 2006 providing varied integrated interventions in line with humanitarian principles and code of conduct as way of ensuring the relief efforts reach the vulnerable communities. Internally IR Somalia has a robust accountability framework and a dedicated monitoring evaluation, accountability and learning (MEAL) coordinator to oversee the implementation of the projects in tandem with community expectation and aspirations.
The organization has close to 350 workforce spread all over Somalia with aim of ensuring the delivery of right amount of relief efforts at the right opportune time when the needs are eagerly anticipated by the beneficiaries. IRS has a human resource manual, IR code of United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
4 conducts and induction package. The staff work rate is monitored through attendance sheet to ensure the smooth implementation of the project.
Nationally, IRS is an active member of the Strategic Advisory Group, Humanitarian Coordination Team (HCT), Clusters (WASH, Health and Education). IR was recently inaugurated as an active member of Return Consortium to secure funds and facilitate the returning of community members to village of origin.
Current programmes of IRS
Health and nutrition programme: - IRS has been providing basic emergency health services in several areas through mobile services and fixed health post. In addition it supports the health Ministries and identified sites with essential medical supplies. In an effort to contribute towards reducing Global Acute Malnutrition (GAM) in particular to Somalia context and more so South Central Somalia; IRS has been rolling out supplementary feeding program to vulnerable children and mothers. For the purpose of sustainability and continuity, IRS normally conducts capacity building trainings. Most of these programmes are funded by DFID, IR-UK, UNICEF, ECHO, CAFOD, DEC and IR partners.
Water and sanitation: - Water and sanitation facility rehabilitation / expansion, training of water resources management committees, water quality monitoring, hygiene promotion campaigns and training communities on good hygiene and sanitation practices. IRS has also been engaged in clean up exercise, refuse collection and provision of latrines as way of improving overall hygiene and sanitation in IDP settings. Funding is by UNICEF, ECHO, private donors and IR UK. IRS has rehabilitated and drilled number of water points (borehole, shallow wells, berkhads and pans) since 2006 as funded by these donors.
Livelihood and food security: in the effort of increasing the resilience to shock through re-building the asset level of drought affected, IRS is supporting farmers in the riverine irrigation along Juba river and micro-finance. Funding for these ongoing projects is from IR private donors, ECHO, IR-UK, IR-Switzerland, DEC and Middle East Emerging Markets (MEEM). It is hoped to receive support for riverine irrigation and water harvesting based irrigation from EC.
Child welfare programme: over 890 children sponsored in Somalia and each receiving $250 each quarter to supplement their basic needs food, health and education needs. Funding is obtained from IR one to one sponsorship programme
1.2 Audit Scope Ernst & Young was contracted by United Nations Childrens Fund (UNICEF) to provide an overall assessment of its implementing partners internal control system. The purpose of the audit is to assess the existence and functioning of an implementing Partners internal controls for the receipt, recording and disbursement of cash transfers United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
5 and the fairness of a sample of expenditures reported in the FACE forms. The period covered under the review was from 1 January 2010 to 31 August 2012. UNICEF also provided an additional scope to the Islamic Relief audit assignment. These are: UNICEF Somalia Projects: 1. Education Project: South and Central Somalia Emergency Education Support focused on the following items: Incentives paid to teachers Human Resource Management Construction of Temporary Classrooms Development of Child Friendly Playgrounds 2. WASH Project co-funded by UNICEF Somalia (75%) and Islamic Relief (25%): Assessment of the IRS access/presence in the Al Shabaab, AS, controlled area; ascertaining the IRSs contribution (25%) to the project and related fund flow; assessment of the water trucking component of the PCA. UNICEF Kenya Project: 1. WASH project: Water and Sanitation facility development in North Eastern Province and Rift Valley (Turkana Central). Review of the overall project implementation and transactions processing. 1.3 Assignment Objectives
The specific audit objectives were as follows:
i) Review of IRs programme management system; under this objective, we conducted the following review procedures:
! Reviewed Project Cooperation Agreement (PCA), Fund Authorization and Certificate of Expenditure (FACE) forms and where applicable; UNICEF relevant manuals, to determine whether requests for disbursements and reports on utilization of cash were provided for activities described in the PCA. ! Through interviews and review of progress reports prepared by IR, established whether activities were implemented as planned. Where activities (timeliness, type, quantity) deviated significantly from the original PCA, established whether this was by mutual agreement by IR and UNICEF. Determined the causes for significant delays or changes, if any. ! Reviewed IRs system of monitoring progress and review of reports, including field monitoring visit reports and progress reports, to assess whether IR met its responsibilities for monitoring as described in the PCA. ! Reviewed whether recommendations recorded in the field/project monitoring reports or minutes of meetings between IR and UNICEF have been implemented by IR. United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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ii) Assessment of IRs internal controls; under this objective, we conducted the following review procedures:
! Conducted a general assessment of internal controls according to established internal controls standards. ! Reviewed whether recommendations made in the micro assessment or previous audit(s) were implemented or, if not, determine the implementation status. ! Reviewed FACE forms, including the request for direct payments, to assess whether they were signed by designated officials of IR. ! Reviewed the processes used by IR for authorizing expenditures and assess whether they are in accordance with the PCA. ! Reviewed the process for procurement/containing of supplies and services and assess whether it is transparent and competitive. ! Reviewed the use, control and disposal of non-expendable equipment and assessed whether it is in compliance with government policies (or UNICEF relevant manuals, where so specified in the PCA; and also, whether the equipment procured met the identified needs and whether it is used in accordance with intended purposes. ! Reviewed relevant IT systems. ! Where UNICEFs funds pay for the personnel or consultants, reviewed the process followed for recruiting IRs personnel and consultants and assess whether it is transparent and competitive. ! Reviewed IRs accounting records and assessed their adequacy for maintaining accurate and complete records of receipt of funds provided by UNICEF and disbursements of cash. ! Interviewed officials of IR, as necessary, to ensure full understanding of the functioning of the internal control system.
iii) Review of sample of FACE forms and transaction testing; under this objective, we conducted the following review procedures:
! Assessed whether the funds received from UNICEF were deposited into IRs bank account by verifying the bank statement. ! Reconciled the expenditure totals, per activity, on the FACEs to the list of individual transactions (i.e IRs accounting records). ! For each activity, reviewed the nature of expenditure and assess the reasonableness. Discuss any concerns with management. ! Selected a sample for testing, carried out a verification of the accuracy and completeness of supporting documentation (e.g. vouchers, invoices, purchase orders, receipt of goods, bank transfers/checks, bank statements) the description of the transaction (per the accounting records) and per the PCA. ! Compared the price paid for goods or services against the market benchmarks. Include other appropriate measures of value for money.
United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
7 1.4 Methodology
The audit was performed using the Ernst & Young audit methodology, which requires general planning and identification of areas of audit significance, as well as evaluating risk inherent in significant accounts.
Our procedures and tests have been tailored to meet the specific objectives of the assignment. Specific procedures performed are laid out in note 1.3.
8
PRIVATE AND CONFIDENTIAL September 20, 2012 60586571/27/sk/777
The Regional Director Islamic Relief P O Box 18089 NAIROBI
Dear Sir, INTERNAL CONTROL REPORT FOR THE PERIOD 1 JANUARY, 2011 TO 31 JULY, 2012 We are pleased to submit our report on the internal control review of Islamic Relief Kenya and Islamic Relief Somalia.
Our review of the organizations systems of internal control is carried out to assess the existence and functioning of Islamic Relief Kenyas and Islamic Relief Somalias internal controls for the receipt, recording and disbursement of cash transfers and the fairness of a sample of expenditures reported in the FACE forms.
We performed our audit as per the agreed terms of references dated 14 August 2012 (UNICEF/AUDIT/IRK/2012-08-002) and as per the assignment objectives laid out in note 1.3 of this report.
We were not engaged to, and did not perform an audit, the objective of which would be the expression of an opinion on the accounts or items thereof. Accordingly, we do not express such an opinion.
This report is intended for the information of Islamic Relief Kenya/Somalia Programmes and UNICEF. However, upon release this report is a matter of public record and its distribution is not limited.
Nairobi
..2012 United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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2. Summary of Findings
We have set out issues identified during the course of our audit and have not attempted to indicate all possible improvements which a special review might develop. This report covers an assessment of the organisations internal control system.
A description of any specific internal control weaknesses noted in the financial management of the organization and the audit procedures followed to address or compensate for the weaknesses. Recommendations to resolve/eliminate the internal control weaknesses noted have been included.
Risk Severity
The audit observations have been categorized by risk severity as high, medium or low. These categories have are described below:
High: Action that is considered imperative to ensure that UNICEF is not exposed to high risks (i.e. failure to take action could result in major consequences and issues).
Medium: Action that is considered necessary to avoid exposure to significant risks (i.e. failure to take action could result in significant consequences).
Low: Action that is considered desirable and should result in enhanced control or better value for money.
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2.1 Islamic Relief Kenya
REF Summary of the issues Risk severity (High/ Medium/Low) 3.1 Expenditure Review 3.1.1 Split Payments for the Same Invoice High 3.1.2 Unsupported Expenditure High 3.1.3 No list of Prequalified Suppliers Medium 3.1.4 Chart of Accounts Low
3.2 Payroll/Human Resources 3.2.1 Late Remittance of Statutory Deductions Medium
3.3 Cash and Bank 3.3.1 Errors in the Bank Reconciliations High
3.4 Fixed Assets 3.4.1 Incomplete Vehicle Log Sheets Medium 3.4.2 Vehicles under Third Party Title Ownership Medium 3.4.3 Controls over Fixed Assets Medium
3.5 Prior Year Recommendations 3.5.1 Prior Year Recommendations Not Acted on. Medium
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2.2 Islamic Relief Somalia
REF Summary of the issues Risk severity (High/ Medium/Low) 4.1 Expenditure Review 4.1.1 Unsupported Expenditure High 4.1.2 Irregular Payments through Galaxy Star High 4.1.3 Incomplete Tender Analysis Forms High 4.1.4 Lack of Evidence on completion of Projects High 4.1.5 Award of tenders to Related/Same Entities High 4.1.6 Uncertified Bank Statements submitted by Bidders High 4.1.7 Inconsistencies in Accountability for Funds Issued High 4.1.8 Attendance List for Teachers with Same Signature High 4.1.9 Counterpart Contribution not Verifiable High 4.1.10 Differences in Quantities Requested and Quantities Paid for High 4.1.11 Construction of Pit Latrines in Mogadishu Benadir Region High 4.1.12 Irregular Purchase of Drugs from Salochin Pharma High
4.3 Cash and Bank 4.3.1 Errors in the Bank Reconciliations High
4.4 Fixed Assets 4.4.1 Incomplete Asset register Medium 4.4.2 Missing Logbooks Medium
4.5 Prior Year Recommendations No prior year audits
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3. Islamic Relief Kenya - Findings on Internal Controls Systems
3.1 Expenditure Review
3.1.1 Split Payments for the same Invoice
Observation
We noted instances where a payment to a supplier was made in several cheques being drawn on the same date. For example Kshs 68,000 was paid to Abdi for tyres for KAV. The payment was paid using four cheques 3713, 3714, 3715 and 3716 each for Kshs 17,000.
Risk
This is done to by-pass authorization limits set by the organization.
Recommendation
Payments made to a supplier to settle one invoice should be done using one cheque to avoid unwarranted bank charges and to maintain audit trail on transactions
Management Comment
3.1.2 Unsupported Expenditure
Observation
There was an instance where one transaction from our sample was not fully supported, as shown below:-
Date No Memo Amount KShs Amount Supported KShs Amount Unsupported KShs 31-Jan-11 GJ 2011/4 Liquidation of Wajir Jan 2011 106,100 79,600 26,400
106,100 79,600 26,400
Risk
Payments may be made for services/goods not received.
Recommendation
All expenditure incurred should be supported with adequate documentation.
Management Comment
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3.1.3 List of Pre-qualified Suppliers not maintained
Observation
We noted that IRK does not have a list of pre-qualified suppliers and thus sourcing of quotations is done randomly to any supplier.
Risk
IRK may not get value for money for the goods/services that it procures.
Recommendation
IRK should have a list of pre-qualified suppliers where quotations are sought. This can be done at the beginning of every year and the list updated as management deems fit.
Management Comment
3.1.4 Chart of Accounts
Observation
We noted that the chart of accounts used in the field is too long. There is no control for the creation of accounts. Field offices can create accounts at their own discretion. The ledger from the field is used to update the ledger in the Nairobi office.
Risk
Lack of control in creation of ledger accounts may be misused as a loop hole for perpetrating fraud. Errors in these accounts may go undetected and therefore uncorrected. Recommendation
The creation of new accounts should be done on approval by designated senior officials of the organizations, possibly the finance manager in Nairobi..
Management Comment
3.2 Payroll/Human Resources
3.2.1 Late Remittance of Statutory Deductions
Observation
NSSF for the months of September 2011 and December 2011 were remitted late as shown below: United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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Month Due Date Date remitted Days Late Sep-11 15-Oct-11 15-Nov-11 30 Nov-11 15-Dec-11 21-Dec-11 6
Risk
IRK may incur penalties.
Recommendation
Management should ensure that all statutory deductions are remitted by the due date to ensure compliance with local regulations.
Management Comment
3.3 Cash and Bank
3.3.1 Errors in Preparation of Bank Reconciliations
Observation
The bank reconciliation statements prepared lacked some important information such as the dates of the outstanding cheques. There were long outstanding items that were still appearing in the bank reconciliation for February 2012 as shown below:
Date cheq no Description Amount KShs 29-Jan-10 2048 NHIF 16,000 19-Feb-11 2117 NHIF 16,000 25-Feb-11 3058 Khalil Building 179,000 25-Feb-11 3219 KPLC 7,990 25-Feb-11 3247 KPLC 2,570 27-May-11 3591 Hussein Ali 283,500
505,060
The bank reconciliations for Garissa, Wajir and Mandera are not revised after being reviewed in Nairobi. The cash book balances for KCB Wajir and KCB Mandera showed a book overdraft due to the field offices writing cheques which were in excess of the funds in the account. This has therefore brought some differences in the amounts in the bank reconciliations and the audited financial statements as shown below:
34,559,263 44,294,385 (9,735,122) United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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There was no evidence that some bank reconciliation statements for Mandera and Garissa were reviewed. The bank reconciliations for May 2011 to Aug 2011 for Mandera were not reviewed while the bank reconciliations for March to May 2011 for Garissa were not reviewed.
Risk
Bank reconciliation is a key control tool and improper bank reconcilations may result in occurence errors and/ frauds being penetrated.
Recommendation
Cheques should only be written once it has been confirmed that there are sufficient funds in the bank account. Bank reconciliation statements should be prepared and have all the vital details such as the dates of the reconciling items. Stale cheques should be reversed once they are more than 6 months old. Bank reconciliations should be reviewed by the finance manager.
Management Comment
3.4 Fixed Assets
3.4.1 Incomplete Vehicle Log Sheets
Observation
We noted that the vehicle log sheets maintained by the drivers are not signed by the staff who uses the vehicle. The log sheets were signed by the driver only and thus this does not adequately control the use of the organization vehicle.
Risk
Vehicles may be misused by the drivers.
Recommendation
The vehicle log should be updated to include two columns for signing, the drivers signature and the staff who uses the vehicle. This will serve as a confirmation that the trip was made and was for the purpose indicated in the log sheet.
Management Comment
3.4.2 Vehicles under Third Party Ownership
Observation
We noted that there are some vehicles maintained in the asset register of IRK whose ownership documents are not in the name of IRK.
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Specific examples include:
Registration Make Holder of Title KBQ 525N Honda CRV AL Husnain Motors Ltd KBQ 067F Toyotal Prado Alinur Maalim Ismail KBR 748c Toyota Hilux Big Motors Ltd
Risk
The vehicles listed in the asset register may not belong to Islamic Relief and thus do not have the title to the same. Further, ownership of such vehicles to IRK cannot be verified. Recommendation
All assets that title vests with IRK should be transferred to IRKs name. Any asset that does not belong to IRK should be not be included in its asset register.
Management Comment
3.4.3 Controls over Fixed Assets
Observation
IRK does not carry out physical verification of its assets. The assets are also not tagged and thus are difficult to trace the assets. The asset register is not complete as it did not include one vehicle, KBR 312P. The asset register did not have accurate information as some assets had a different price in the asset register as compared to the actual invoice as shown below:
Date Description Invoice Amount KShs Amount as per Asset Register KShs Difference KShs 02/08/2012 GPS 36,000 35,000 1,000 03/06/2012 Mobile phone 28,000 23,999 4,001
Total 64,000 58,999 5,001
Risk
Islamic Relief is not able to ascertain the physical existence and working condition of the assets if it does not conduct a regular verification of its assets.
Islamic Relief may also not be able to keep track of its assets if the register is not updated with the accurate details.
Recommendation
Physical verification should be done at least once a year and the asset register updated with the information obtained from the exercise.
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Management Comment
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3.5 Prior Year Recommendations
3.5.1 Prior Year Recommendations not acted on
Observation Prior year observations are tabulated below with recommendations there on and current status.
Observation Recommendation Management Action
1
Weak procurement Process
i) The organization did not maintain a record of bidders who had participated in the tendering process ii) Insecure public email addresses were provided as an alternative for bids submission. iii) Some procurement payments were supported with suspect quotations. iv) A tender box had not been installed in the premises for submitting bids. v) Bidders were not invited to witness the opening of bids. vi) The Local Purchase Book (LPO) was not securely kept under key and lock. vii) Some tenders were issued 2 days to the tender submission deadline viii) An open tender for the supply of food packs had always attracted only 3 bidders for all the sampled vouchers for period under view. This was despite the tenders being advertised in national newspaper. The same suppliers had interchangeably won tenders on the different occasions. ix) Two different suppliers of food packs (Fahma Traders and Vein Logistics) for relief of drought and Ramadan had the following suspect similarities; Same format of invoice and delivery notes; Both provided one cell phone number appeared to be by
i) The organization should urgently review its procurement policy in order to enhance competition and transparency by; Prequalifying suppliers / contractors for regular supplies and services for efficiency in procurement process and to avoid dealing with unknown suppliers / contractors. A procurement file for each tender / procurement should be maintained with record of all participating bids, advertisement, procurement committee meeting minutes, copy of contract / order for audit trail and institutional memory. A tender box should be installed in an open location within the office. Access to the tender box and emailing address should be controlled to reduce chances of bids being maliciously removed from the tender box or emailed bids being deleted. The tender advertisement should indicate the date of tender opening and invite willing bidders to witness the process. Tenders should provide a reasonable time for potential bidders to apply before the deadline for submission and opening of tenders. This would
Management recognized the weak procurement process and has so far instituted controls that will see a more transparent procurement process and value for money being realized. In the period through and after the 2009- 2011 audit, the following measures have been instituted in order to ensure that the weak areas are eliminated from the whole process: -Operations Manager who was in charge of procurement has left the organization -A new Operations Manager has just been recruited; the new OM has huge experience in dealing with USAID and OFDA procurements among other donor funding; this is a great advantage for IR Kenya as the USAIDs United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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Observation Recommendation Management Action the same writer as their address without indicating their physical address on their invoices; Handwriting on the invoices; Company profiles for the two were not be availed for audit; Always the competing bidders on every occasion the tender is advertised; x) All bidders for supply of food packs including the winning supplier did not indicate their physical address on their invoices. xi) Bid analysis was done before or on the bid submission end date. xii) Suspicious legal documents e.g Registration Certificate, PIN, Tax Compliance Certificate had been used to support some of the winning bids. xiii) Supplier files were not maintained
reduce the risk of locking out more competitive bidders from participating. The organization should explore the benefits of outsourcing the tendering process to increase efficiency and transparency. This would reduce incidences of insider interference.
ii) Due diligence should be carried out on future selected suppliers / contractors on their physical location, ownership, capacity to deliver before a contract / order is signed / issued. iii) A supplier file for pre-qualified suppliers should be maintained with information on; registration, ownership, copies of contracts / orders, copies supplier invoices / fee notes for audit trail and institutional memory. iv) An investigation should be carried out to check on possible fraud and appropriate measures taken to prevent any future occurrence of the same. Suppliers found to have been involved in any unfair competition practice should be suspended from participating in any future tenders.
stringent procurement practices shall be replicated to strengthen the IR Kenya procurement process. -The procurement committee has been revamped to include; Finance Manager, Head Programs section, Operations Manager and a technical representative. It is intended that these office holders shall in as much as possible be present to attend tender opening process otherwise they are represented by selected representatives. -In order to establish genuineness of potential suppliers, no supplier shall be selected without company profile and a verification of PIN authenticity from the KRA online website. -The management has agreed to the fact that suppliers/bidders (or their representatives) are invited to take part in the bid opening process. To commence with the next tender process -Reasonable time shall be afforded for tender advertisement so that no bidder is locked out of the United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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Observation Recommendation Management Action tender process. -The management has agreed to embark on a supplier pre- qualification process for those supplies with expertise on IR Kenyas main items of procurement. This process has already begun; what now waits is the analysis of the prequalification bids.
2
Questioned Payments
i) Some payments made in the field had the following issues: Digits altered to increase the paid amount thus unapproved payments. Inconsistent details of recipients; ID Numbers and signatures. Recipients signatures seem to have been signed by the same person. Wages paid were not supported with contracts. Suspicious supporting receipts attached Large amount paid in cash instead of cheque payment. ii) A payment of KES. 300,000/= was supported with a bank deposit receipt of KES. 30,000/= instead of KES. 300,000/= iii) Water trucking sheets seem to have been filled and signed by the same IRK staff who prepared the form. Water trucking sheets are supposed to be signed by community members on delivery of the water. iv) Some of the sampled suppliers / contractors were paid in cash instead of cheque payment. v) Cash payments were made to government line ministries supported with requests on suspicious letters heads. vi) Suspicious double payment for the same service / contract.
i) We advise the management to investigate the suspected fraud in the above findings/cases and where it is confirmed, the misappropriated amounts should be recovered from the concerned staff. Disciplinary action as per Islamic Relief Kenya human resource policy should be taken against the staff involved. Suppliers found to have been involved in any unfair competition practice should be suspended from participating in any future tenders. ii) The management is advised to always issue casual workers with contracts with terms of engagement, period, ID number, telephone contact and pay amount. Wage payments should be supported with copies of the signed contracts and attendance register. This would reduce the risk of paying nonexistent casuals or alteration of amount paid. iii) Islamic Relief Kenya should explore the advantages of outsourcing some project implementation works e.g; slaughter of Ramadhan goats, loading / off loading of food packs, waste disposal, digging of wells etc to local competent
There have been instances where fraudulent staff have been involved in alteration of documents among other malpractices, the management recognizes the negative impact this has so far instituted the following measures; -The organization has instituted controls to curb any future possibility of documents alteration; though spot checks of field offices and improving competency of field finance staff. -Support documentation checklist has been developed, reviewed and begun implementation. -Limits of amounts made in cash has been instituted and followed up; any amount paid United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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Observation Recommendation Management Action contractors. IRK staff could be involved at the supervision level. This could reduce the risk of fraud in casual payments, minimize the risk of handling of large sums of cash and transfer other liabilities due to work related risks to the contractor. iv) Internal controls on payments should include review of support documents for; arithmetic accuracy, authenticity, consistency, reality and where possible random third party confirmations by calling recipients. This would ensure only genuine expenditure are authorized and minimize chances of double payments. v) Cash payments to casuals and workshop / training participants should be supported with a signed attendance register. Where possible, the register should include own handwritten names, ID / Passport number, date, telephone contact and location. vi) Large payments to suppliers should be done by cheque to avoid risks associated with carrying large sums of cash.
to a single supplier exceeding KES 5,000.00 is made by cheque. Amounts higher than KES 5,000.00 are always paid in cash except under circumstances where areas are remote and beneficiaries do not own bank accounts, but this is clearly justified beforehand. -The use of attendance sheets in the payment for allowances is being used at all times, ensuring that attendants sign it on each day of training with own handwriting. -All casual engagements are done with a simple contract, indicating the name, ID number, amount to be paid; before payment is done, the contracting department signs to verify that the works done is in accordance with specifications. -Payments to government representatives are done in accordance with fully verified requests and their allowances are paid in accordance with the government published rates. -Before payments are done; the Finance Manager takes United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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Observation Recommendation Management Action time to verify them for arithmetic accuracy, authenticity of documentation and compliance with IR Kenyas internal controls and donor regulations.
3
Orphan 1-2-1 and OMEP Project
i) Payments under Orphan 1-2-1 and OMEP project were withdrawn in cash from KCB Mandera and deposited to various bank accounts instead of bank transfer. This includes Kes. 6,300,110/= withdrawn by an IRK staff on 24/3/2009 against required procedure. ii) A cash withdrawal of KES. 2,400,000/= from KCB Mandera and deposited to various CBO accounts in the same bank instead of a bank transfer. One of the supposed deposits was supported with deposit slip of KES. 30,000/= instead of KES. 300,000/=. iii) Equity Bank only confirmed transfer of funds by a letter and by stamping the list of beneficiaries provided by IRK. No bank statement was attached as evidence of payment. iv) No Memorandum of Understanding (MOU) had been signed between Equity Bank, Mandera and Islamic Relief Kenya outlining their terms of agreement in dealing with these payments/transfers. v) We established that an IRK staff was one of four the signatories to Mandera Micro Credit Group bank account against procedure. A review of one of the letters to the bank revealed that the other three signatories could only sign by a thump. This contradicted with the representation by IRK field staff and from details of the MOU with Mandera Micro Credit Group. vi) Equity Bank, Mandera wrote letters to IRK confirming transfer of funds from Mandera Micro Credit Group account to OMEP beneficiaries even though IRK was not the account holder. It is
The management is advised to urgently investigate the various funds transferred under the two projects and also randomly visit and interviewing various beneficiaries on the different lists. Where fraud is confirmed, disciplinary measures should taken against the concerned staff as per Islamic Relief Kenya policy Legal due process should be taken against any persons involved and recovery process for any lost funds be done.
We also recommend suspension of all future funds transfer by Islamic Relief Kenya to Equity Salary Suspense account and Mandera Micro Credit Group account. The organization is advised to open a bank account with Equity Bank from where funds shall be transferred to beneficiaries bank accounts.
Where collusion with bank branch staff is suspected, an independent confirmation be made with the Equity Bank head office and further investigation into transaction between Mandera micro-credit group and beneficiaries. All future deposits to beneficiary bank accounts should be done by a bank transfers or cheques.
In response to the audit findings above, the management has instituted the following measures in an effort to ensure that transfers for One-to-One and OMEP disbursements reach the intended beneficiaries and in the most effective and compliant means. -All payments to the One-to- One orphans was done direct from the IR Kenya Barclays bank in Nairobi to their respective bank accounts as opposed to a withdrawal from the IR Kenya KCB in Mandera and deposit into Equity bank. -All payments to the OMEP are done direct from the IR Kenya Barclays bank in Nairobi to their respective bank accounts as opposed to a withdrawal from the IR United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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Observation Recommendation Management Action expected that confirmations were to be addressed to officials of Mandera Micro Credit Group who were the account holders. This raised questions of the relationship between the group and IRK given the legal status of the group. vii) A review of the Mandera Micro Credit Group bank statements revealed lumpsum debits to the bank account instead of split payments to the various beneficiaries bank accounts. viii) We noted that the following payments under OMEP II had been withdrawn from KCB bank and deposited into Equity Bank Salary Suspense Account instead of Mandera Micro Credit Group or Group accounts for distribution {see annexure III(b) for details} ix) Equity Bank does not issue statements of account for funds transferred through the Salary Suspense account to confirm payments/transfers. x) A letter (internal memo) dated 1/12/2010 to Equity Bank to debit Mandera Micro Credit Group bank account with KES.630,000/= was a refund for the funds was made by a cheque to Mandera Micro Credit Group on 19/4/2011. The same amount of Kes. 630,000/= was withdrawn from KCB bank account and deposited in Equity Salary Processing account on 17/5/2011. xi) The following inconsistencies were noted on the Islamic Relief Kenya transactions with Equity Bank, Mandera; - Suspicious letters on a template format with a substandard presentation. - The rubber stamp that was used on the letters and beneficiary list was different from stamp used on deposit slips and bank statements by Equity bank. The stamp was smaller in size, lacked inscribed date and position holder. - The bank accountant we interviewed introduced himself as the acting branch manager. This contradicted his later confirmation that either the Assistant Branch Manager, Operations manager, or Treasury Manager could act as branch manager in his/her absence. Kenya KCB in Mandera and deposit into Equity bank. -Islamic Relief Kenya and Worldwide intends to engage a consultancy so as to come up with a more viable way to implement the OMEP project, this will also involve the relationship IR Kenya will have with the micro enterprise group. To commence once the HQ finalizes the process. -IR Kenya intends to undertake an investigation into the alleged collusion between IR Kenya staff and Equity bank representatives in order to objectively establish the actual status of affairs. Upon obtaining the findings, IR Kenya will take the necessary action in accordance with the existing procedures. This has been done and nothing substantial relating to collusion was established. IR Kenya shall carry on with strengthening its internal controls so that United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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Observation Recommendation Management Action - No reason was provided for by IRK for not operating a bank account with Equity Bank, Mandera to process beneficiary payments. With a bank account IRK could be issued with bank statements confirming how funds had been paid to the beneficiaries. - We could not independently verify the authenticity of Excel sheets provided by the IRK staff as bank ledger to evidence credits to various beneficiaries including a credit to a bank account with KES. 41,630/=.
such practices shall not be experienced in the future.
4
Payroll and Statutory Compliance
IRK is statutory required to deduct from its local employees and expatriates and remit; PAYE, NSSF and NHIF to respective bodies. IRK is also required to file annual returns with NGOs Board by the 30 th May of each year. Some of these were delayed while there was no evidence of remittance for some months.
The management should ensure that all expatriate staff have valid work documents in compliance with the Kenyan immigration laws. Where issuance is delayed, applicable taxes should be deducted, accrued and paid once the permit has been issued. The management is advised to correctly compute deduct and remit tax accruing from employee and expatriates income using prevailing tax rates and remit the same to KRA to avoid possible penalties and fines by KRA. All disallowable benefits including medical cash allowances should be included in the taxable of employees. All statutory deductions from staff should be timely remitted to avoid penalties and fines. Management is advised to move with speed to apply for renewal of the tax exemption certificate. We recommend consolidation of Islamic Relief Kenya and Somalia programme financial transactions to correctly report the financial position of Islamic Relief financial transactions.
The management has been able to ensure compliance with the following in an effort to abide by the prevailing legal and institutional requirements. -All expatriate staff engaged with IR Kenya now have valid work permits; no expatriate is allowed into the country without due process and a valid work/residence permit. -All expatriate staff remit their due takes in time as other national staff - by 9th of the next month. -No staffs now receive cash for medical allowances; medical services are contracted to an established United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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Observation Recommendation Management Action provider (APA insurance company). -Islamic Relief Kenya and Somalia is looking into consolidating their accounts once the audit process for IR Somalia is completed. This has been agreed with the IR HQ.
5
Fixed Assets Management
i) Some sampled assets purchased costing more than $ 500 had been expensed. ii) Fixed assets register was not updated, some assets were missing from the fixed asset register. iii) Other than motor vehicles, all other assets had not been insured.
Management is advised to consistently apply the organizations policy on capitalization of assets valued at $ 500 or more for fixed assets purchased. Any change to the policy should be documented for consistency.
The asset register should always be updated with movement in assets including additions and disposals. This would enable proper tracking of the assets.
The management is urged to evaluate the benefits of taking insurance cover on assets to mitigate financial loss in the event a theft or any natural calamity happening.
In response to the lack of proper adherence to policy, lack of proper documentation and unrepresentative asset register, the management has instituted the following: -Employment with a competent and experienced Operations Manager who will be tasked with standard tasks like; routine updates of assets register, evaluate and explore the cost/benefit of insuring assets other than vehicles among other compliance items. -The management has requested the logistics department to furnish it with United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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Observation Recommendation Management Action monthly updated assets register, which will include additions and disposals for the reporting period. -Staff capacity building is currently under implementation, in order to ensure that all aspects of assets management practices are adhered to.
6
Cash and Bank Management
A review of the cash and bank balances internal controls indicated that:-
i) No regular cash reconciliations were prepared for period under review. ii) Lack of segregation of duties; the staff who prepares payment vouchers, also writes the cheques, records payment transactions in the cashbook and acts as the official bank agent (authorized to withdraw cash from the bank). iii) Most bank reconciliations were prepared late with backdated signatures. iv) Cash levels in excess of the minimum allowed of KES.50,000 /= balances were kept in the office. v) Payment to some of the contractors were by cash instead of cheque as the preferred mode of payment. vi) All sampled cancelled cheques did not have reason for cancellation indicated on them.
The management is urged to adhere to its financial guidelines on cash by ensuring that cash reconciliations are prepared at least once a week and reviewed by the supervisor. The reconciliation certificate should be filed for. Impromptu cash counts should be performed by the supervisor to confirm cash balances. This will reduce risk of misappropriation of cash. The management is encouraged to explore ways of segregating duties in the finance departments by separating duties of staff who initiate payments from writing of cheques and withdrawing of cash from the bank. This would minimize risk of fraud arising due from lack of segregation of duties. Bank reconciliations should be prepared on a monthly basis within a reasonable time, preferably before the 10th of the following month. This will enable timely correction and minimize chance of errors or mistakes passing
The management acknowledges weak points relating to cash and bank practices and has so far instituted the following measures: -Bank reconciliation is done through the QuickBooks system as opposed to the excel formats; this is done by the 5th of the next month, reviewed and approved by a supervisor. This is also dated. -Cash payment vouchers are now being used to make payments as opposed to the use of journals; each cash payment is verified and approved before payment is made. United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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Observation Recommendation Management Action unnoticed on bank statements / cashbook. Management is advised to always pay suppliers / contractors by cheque. Cash should only be used for paying sundry office and field expenses. -Cash reconciliation is performed on a routine basis through the system; and each time before more cash is requested. -There now is a separate staff for making payments while the other does data entry; this ensures segregation of duties between those making payments and those recording those payments.
7
Consultancies and Contracting
i) Withholding tax was not deducted on all the sampled labour fee charged by works contractors. ii) Some of the sampled consultants were paid as casual workers without deducting Withholding tax for amounts that qualified for deduction. iii) Certificates of work completion issued to consultants and contractors were not dated.
The management is advised to adhere to the Income Tax requirements on Withholding tax. Withholding at the rate of 3% on all labour fees should be charged and remitted to KRA before the 20th of the following month. Where the contractor does not distinguish between labour fees and cost of materials, the tax should be charged on the total invoice amount. All other short-term contractors paid at least KES. 24,000/= should be charged withholding at the published rate and remitted to KRA by the 20th of the following month to avoid possible fines and penalties by KRA. We advise the management to include a provision for date on certificates of work completion to help in verifying compliance with contract terms on job completion.
-Withholding tax of 3% on all construction contracts is now deducted as source and submitted to the Kenya Revenue Authority. -Consultancy tax of 5% is now deducted at source and submitted to the KRA. -On all construction contracts, the respective technical departments contact person verifies that the work is done in accordance with the contract before payment is done. This is in form of a completion certificate.
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Observation Recommendation Management Action
8
Accounting System i) Field office control accounts were not reconciled with the Nairobi office balances. ii) We noted double booking of accruals in books of accounts while some expenses had not been accrued in the financial records. iii) Some prepaid expenses had been expensed instead of being recognized as a receivable asset until utilized. iv) Deposits made during the period under review were not recognized in the financial records but expensed. v) Mandera and Wajir cash books had negative balances.
The management is urged to always apply the recommended accounting standards on income and expense recognition by matching incomes and expenses to the period they were incurred. This would lead to consistency and correctness in financial reports
-IR worldwide has begun implementing an online finance system, it will soon be rolled out in the field offices including IR Kenya; as this system is superior to the QuickBooks software currently being used, this will go a long way in enabling accurate recording of expenses. -IR Kenya Finance Manager is currently looking into the benefit of having a different QuickBooks company in the field offices as opposed to a similar company both in Nairobi and in the field offices. -The Finance Manager is looking in to other ways of tracking field transfers and expenses in the place of control accounts, as at now, control accounts do not serve their purpose. -The Finance Manager intends to ensure accrual recording is centralized to avoid situations where accruals are double- posted. Also the FM is moving to ensure that accruals is only done based on Contracts/POs/Invoices and United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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Observation Recommendation Management Action not based on invoices as is currently done in some instances.
9
Accounting for Advances
i) Some of the sampled project cash advance payments had been directly expensed before the actual expenditure was accounted for by staff. ii) There were no adequate procedures governing accountability of project cash advances. The documented procedures lacked guidelines on the period for accounting for staff advances. iii) Some liquidations had suspect supporting receipts / documents. iv) Staff advances amounting to KES. 827,151/= had been written off in the year 2010 without proper explanations. v) We noted long outstanding advances some more than six (6) months old. vi) No traceable log-in password in the multiuser QuickBooks accounting systems
Management is advised to review and update procedures on staff advances to ensure proper management e.g all cash advances to be authorized by a designated officer and recorded in the books of accounts as a receivable, each advance should be booked to individual staff ledger account for ease of tracking. After accounting for such advances, the expenditure should then be recognized. Supporting documents should be attached to float liquidation forms, reviewed and authorized before the expenses are posted into the system. All unutilized advances should be immediately surrendered to the cashier. The policy should provide maximum period for float liquidation. Un-surrendered floats after the expiry of the time limit should be recovered from staffs salaries. The suspect receipts /documents should be received and verified for authenticity and corrective action taken. Additional tests should be done on all other staff advances taken during the period. All uncollectable advances should be properly and adequately explained before being approved for write off. All long outstanding advances should be reviewed and necessary action taken to recover them, where uncollectible approval for write off should be sort.
In order to further strengthen staff advance procedures, the following safeguards are currently being implemented;
-Staff advances are only given in situations where a direct payment via cheque to a supplier/service provider is not feasible and practical. -When staffs are issued with an advance, its immediately recorded as a receivable in the accounts; this is then expensed when the advance is accounted for. According to IR Kenya procedures, staffs are given a maximum of 10 working days after completion of the activity to liquidate advances. United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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Observation Recommendation Management Action We also urge the management of review of the current policy manual to suite the local operational environment.
10
External Audits
i) The latest external audited reports were for year 2008 accounts which were signed off in the year, 2012 3 years late).The 2009, and 2010 audits have been concluded in year 2012 ( 2 years and 1 year late respectively) ii) The 2008 management letter was not availed for audit. iii) Lack of internal audit and monitoring department.
Management is urged to ensure that external audit to review the internal controls of the organization and the books of accounts as provided for in the IRW financial guidelines and in compliance with statutory requirements is concluded on time. The external audit gives an assurance that accounting standards have been adhered to, and that statutory and professional rules have been complied with and the report is a 'true and fair' representation of the affairs of the organization. Where the audit is done late, the organization may miss the benefits of promptly improving the internal controls where the auditor recommends.
The external auditor should be required to issue management with a management letter audit findings to be discussed by the management and actions on how the organization will address the issues highlighted put in place with timelines. The management letter should be submitted to the head office as provided for in the financial guidelines. We advise the management to explore the possibility of outsourcing internal functions to perform routine reviews of the procedures.
The management has agreed to ensure that there will be no more delays in undertaking annual audits; the 2012 external audit shall be carried out by Feb/March 2013 as provided by IR regulations. The management also will look into ways of engaging internal audits to establish and advice on the status of internal control systems.
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Observation Recommendation Management Action
11
a) Finance In the field offices, the finance officer has both custody of assets and the accounting roles. For example, same staff prepares payment vouchers, maintains and writes and cheques, is also the bank agent. He / she is also in charge cash book and prepares reconciliations.
b) Procurement The logistics is responsible for writing Purchase Requisition Notes, receives quotations, sits on the procurement committee, writes and authorizes the L.P.O. and receives delivery of procured goods.
User department line manager(s) approves Purchase Requisition Note, chairs the procurement committee, and authorizes payment. One line same manager also is a bank signatory.
c) Consultancy The programme manager (single) sources for consultants, drafts terms of reference, negotiates consultancy fee, countersigns the contract, issues the work completion certificate, approves payment and signs the cheque/bank transfer.
The management is advised to come up with a risk assessment tool that that reflects the probable risk exposures in line with Islamic Relief Kenyas type of operations.
Finance: There are two finance staffs in each field office, finance officer and finance assistant. Finance officer is charged with supervisory, verification and field authorizations while the finance assistant, is responsible for making payments and recording them. The recorded transactions are reviewed by the finance officer before they are sent to Nairobi for further verification by the staff in Nairobi. In the Nairobi office, there is segregation of duties in most of finance tasks; one finance assistant prepares payments while the other records them. Finance officer reviews the recorded transactions for accuracy. Finance Manager does overall review and approval of all financial transactions. Procurement: Purchase requisitions are written by the requesting department; after its all approved, they are sent to the logistics staff who will in turn source for quotations and since there are more than United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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Observation Recommendation Management Action one logistics staff for each field office, there is segregation of duties as its not the same staff who sits in the committee who also receives the goods. LPOs are written by logistics staff but verified by the Operations Manager before signed by the country director. Consultancy: Request for consultants is done by the respective technical department, they also do the terms of reference; the service is then advertised in the national newspapers, quotations are analyzed by a penal constituting the head of programs, M&E and the requesting department. Completion certificate is done by a representative of the technical department
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Risk
Significant weaknesses may still recur.
Recommendation
Prior year audit recommendations should be acted on to avoid recurrence of issues in subsequent audits and to improve on the organizations internal control.
Management Comment
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4. Islamic Relief Somalia - Findings on Internal Controls Systems
4.1 Expenditure Review
4.1.1 Unsupported Expenditure
Observation
There were instances where some transactions were not supported while others were inadequately supported, as shown below:-
Date Document No. Description Amount KShs 21-Mar-12 JVN12/3/118 Water Trucking 1,777,792
Total 1,777,792
Food distributed to the communities made by Islamic Relief did not have a signed list to show acknowledgement of receipt by the beneficiaries. However, community representatives, IRS distribution and monitoring staff sign the distribution.
Payments may be made for services/goods not received.
Recommendation
All expenditure incurred should be supported with adequate documentation.
Management Comment
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4.1.2 Irregular Payments made through Galaxy Star International Trading Limited
Observation
We noted that payments to some destinations in Somali are made through Galaxy Star International Trading Limited. Galaxy is company headquartered in Dubai and with offices in Nairobi and Mogadishu. The agreement between Galaxy and Islamic Relief states that Galaxy shall transfer funds on behalf of the NGO to specific locations in Somalia at a commission charge of 1.6% of the total funds transferred.
The use of agent to transfer funds may indicate that Islamic Relief may not have access or presence in the Al Shabaab controlled areas.
For example Dalmar Fuel Company supplied clean water to 3 Districts in Somalia at a cost of USD 13,650. In the invoice dated 15 March 2011 the company supplied their bank details. Islamic Relief transferred the funds through Galaxy instead of transferring the funds directly to the bank account details provided by the supplier.
We were not able to justify the reason why suppliers in Somalia were being paid through Galaxy instead of being paid directly to the suppliers in their indicated bank accounts
Risk
Fraud/Money laundering may be easily perpetrated.
Recommendation
Further investigation should be considered to determine the presence of Islamic Relief in these areas and whether funds transferred through Galaxy are for the intended beneficiaries or Galaxy itself.
Management Comment
4.1.3 Incomplete tender analysis forms
Observation The tender analysis opening tables had not been completed in several instances including bids for Class rehabilitation, value USD 290,555, awarded to Barwaqo Trading and Construction Company and Construction of temporary classrooms, value USD 102,851, awarded to East African Construction Company. There was no evidence of detailed technical analysis of the bids on file.
Risk
Islamic Relief may collude with the suppliers to award tenders to specific suppliers.
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Recommendation
Further investigations should be conducted to identify the owners of the companies being awarded tenders irregularly. The purpose of the investigation will be to identify if there is a conflict of interest being exhibited by the management of Islamic Relief by virtue of ownership of supplying organisation
Management Comment
4.1.4 No evidence of completion of projects
Observation
We noted that the infrastructure projects awarded to East African Construction Company and Barwaqo Trading and Construction Company, project reports and photographs of the completed projects or projects under implementation were not on file.
These projects were worth a total of USD 393,406, as detailed below:
Reference Recipient Value (USD) JVN 12/5/103 Barwaqo Trading and Construction 290,555 JVN/12/5/102 East African Construction 102,851
Total 393,406
Risk Payment may have been made to the construction companies for construction not yet done.
Recommendation
Field visit should be conducted by an independent person/organisation to confirm whether these projects were fully implemented. The independent person will be expected to provide a report on the current status of these projects.
Management Comment
4.1.5 Tenders Awarded to Related/Same Entities
Observation
We noted that East African Construction Company, Barwaqo Trading and Construction Company and Doy Construction Company submitted several documents including bank statements and company profiles while bidding for construction and rehabilitatiaton projects. United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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We also noted that parts of their company profile documents had similar formats, including headers and font styles and their bank statements were all unsigned and unstamped and also originated from the same bank.
This implies that these three companies are related or are under the control of the same entity; or that these documents were prepared by the same person.
Risk
The tender analysis done may not be of value as the quotations provided originate from one source.
Recommendation
Further investigation should be considered to ascertain the authenticity of these documents and the relationship of the three construction companies.
Management Comment
4.1.6 Uncertified bank statements submitted by bidders
Observation
East African Construction Company, Barwaqo Trading and Construction Company, Doy Construction Company and Illays Construction Company submitted unsigned and unstamped bank statements from Dahabshil Bank as part of their bid documents. This is unusual as standard procedure for many banks is to sign/stamp statements intended for use by a third party, as proof of their validity.
The Dahabshil bank confirmation provided by another bidder (Jubba Valley Railway) were signed and stamped by the bank manager, unlike the other documents described above.
The bank statement submitted by East African Construction Company contained two transactions bearing the same reference (Ref 5785675). The values of these two transactions were different - one USD 380,000 and the other USD 82,000.
All other transactions in this and other bank statements were serialised, with there being no other transactions with the same single reference, unlike in this specific incident.
Risk
The bidders submitting their tenders may not be the actual account holders.
Recommendation
Further investigation should be considered to ascertain the authenticity of the bank statements. United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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Management Comment
4.1.7 Inconsistencies in accountability for funds issued
Observation
We noted that in the supporting schedules to journal voucher JVN12/6/202 for USD 53,760 (Payment of teachers' incentives) the telephone numbers of individual teachers were used as part of their identity criteria. Telephone number 615769696 was used to represent two teachers, for two different payments of USD 420, as was telephone number 6153556.
Risk
Double payments may be made to some teachers.
Recommendation
Further investigation should be conducted by an independent person/organisation to verify the presence of teachers in the various schools.
Management Comment
4.1.8 Attendance lists for teachers
Observation
We perused the attendance list for teachers and noted that in some instances the signature was similar for all the teachers.
Risk
Double payments may be made to some teachers.
Recommendation
Further investigation should be conducted by an independent person/organisation to verify the presence of teachers in the various schools.
Management Comment
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4.1.9 Counterpart Contribution not Verifiable
Observation
The WASH project is funded by UNICEF and Islamic Relief at 75% and 25% respectively. We found that there are 27 projects whose funds are banked in one Barclays Bank account. The funds from various donors are commingled in one account. Since all the projects use one account, it was impossible to ascertain the 25% Islamic Relief contribution to the WASH project.
Risk
Islamic Relief may not be meeting its contractual obligation of contributing its 25% share of the budget.
Recommendation
A reconciliation of all the donor funds banked in Barclays Bank Account should be conducted to verify whether Islamic relief has been providing 25% of the required funding.
Management Comment
4.1.10 Differences in Quantities Requested and Quantities Paid for
Observation
Islamic Relief entered into an agreement with Dalmar Fuel Company in respect to emergency response water supply on 8 March 2011. The agreement was to supply 8 trucks of 10,000 litres of water to villages around Galdogob (total 80,000 Litres), 6 trucks of 10,000 litres of water to villages around Harfo (total 60,000 Litres) and 7 trucks of 10,000 litres of water to villages around Jariban(total 70,000 Litres).
We noted that contrary to this agreement, Dalmar Fuel Company invoiced for 800,000 litres, 700,000 and 700,000 litres respectively This represents a loss of USD 25,605.
Dalmar Fuel Company seems to be primarily a fuel company given its name and company logo.
Risk
Islamic Relief may have paid for goods not received.
Recommendation
Further investigation should be considered to determine the actual quantity of water supplied, the reason for the inflated invoices and the nature of this company.
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Management Comment
4.1.11 Construction of Pit Latrines in Mogadishu Benadir Region
Observation
Tayo Constructon Company was awarded the tender to construct pit latrines in Mogadishu Benadir Region. We reviewed the documentation and noted that the following mandatory pre-requisite documents as per the check list payment were not attached before the payment was made: There are no 3 mandatory quotations attached. However there is an undated Bill of Quantities which is not printed on the companys letterhead. Bid evaluation form Purchase Order Invoice Photos Company/supplier registration copy Screening compliance
Islamic relief issued a certificate of completion to Tayo Construction Company through Ashir Ibrahim Nageye. We noted that the certificate was issued on 15 April 2012. The certificate indicates that the project commenced on 20 th March 2012 and completed on 29 April 2012. The issuance of the certificate before the completion date casts doubt on the construction of toilets.
Risk
Staff from the two companies may be colluding to perpetrate fraud.
Recommendation
UNICEF Somalia should consider instituting further investigation to confirm that the pit latrines were constructed.
Management Comment
4.1.12 Purchase of drugs from Salochin Pharma
Observation
Islamic Relief purchased medicines for Health Facilities in Afgooye through LPO number S/5334/11 dated 15 April 2011 at a cost of Kshs 6,182,398.00. We noted that the quotation received from Salochin Pharma was dated 16 April 2011. This implies that the LPO was issued before a quotation was received. We perused the bid evaluation form and noted that the document was undated and therefore we could not ascertain when the evaluation was done. However, we noted that the other quotations from other United Nations Childrens Fund (UNICEF) Internal Control Review Report Islamic Relief
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bidders; Rangechem Pharm Ltd, Ansell Pharm,. Ltd and Surgik Pharm. Ltd were dated 15 April 2011.
Risk
There may be cases of collusion between the Islamic Relief staff and the supplier.
Recommendation
Further investigation should be considered to determine whether the bid was fixed to favour Salochin and which Islamic Relief staffs were involved in violating organisations procurement procedure.
Management Comment
4.2 Payroll/Human Resources
4.2.1 Incomplete Personnel Files
Observation
We noted that some personnel files lacked crucial documents. These include:
Name Position Documents Missing Abdullahi Ahmed Media Coordinator Academic,C.V. and Professional Certificates Abdirisak Hassan Project Support Coordinator Academic and Professional Certificates Mohamed Adan Ali Logistics Coordinator Academic and Professional Certificates Mohamud Ali Mohamed program Coordinator Academic and Professional Certificates Alinur Ibrahim Sheikh Nutrition Officer Academic and Professional Certificates Alex Maingi Finance Coordinator Academic and Professional Certificates Hassan Abdi Mohamed Programme Assistant Academic and Professional Certificates Amos Cherogony Wash Project Manager Academic and Professional Certificates Anthony Nyota IT Officer Academic and Professional Certificates Abdirizak Hussein Food Security Coordinator Academic and Professional Certificates
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Risk
Employees hired may not have the requisite qualifications if they do not produce their certificates
Recommendation
Personnel files kept should have all the relevant information that pertains to an employee.
Management Comment
4.3 Cash and Bank
4.3.1 Errors in Preparation of Bank Reconciliations
Observation
The dates of preparation and review of bank reconciliations are not indicated and thus we could not ascertain their timely preparation or review. Outstanding cheques are also not dated and thus it is difficult to know which cheques are stale. There was a long outstanding cheque (No. 102557) of KShs 22,400, which had gone stale and still appeared in the bank reconciliation statement of June 2012.
Risk
Errors in the bank reconciliation statements may lead to misstatement of the cash balances.
Recommendation
Bank reconciliations statements should be dated on preparation and on review. All stale cheques should be reversed.
Management Comment
4.4 Fixed Assets
4.4.1 Incomplete Asset Register
Observation
The assets register is incomplete as it lacks key details such as the assets tags/ registration numbers of some vehicles. This makes it difficult to physically identify the assets.
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Risk
Islamic Relief may not be able to keep track of its assets if the register is not properly updated with the correct details. Recommendation
The assets register should be kept up to date with key details that can be used to identify the specific assets.
Management Comment
4.4.2 Missing Logbooks
Observation
Vehicle logbooks for all vehicles were not provided for our review and thus we could not ascertain whether the title of the vehicles vests with IR Somalia. IR Somalia does not keep the log books in their possession of all the vehicles in the field.
Risk
The vehicles listed in the asset register may not belong to Islamic Relief and thus do not have the title to the same.
Recommendation
Vehicle logbooks shows the owner and thus for all its assets, IR Somalia should have legal documents as proof of ownership.